EMC China Lab

European Regulation PPWR Testing Services

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Update time : 2026-11-04

The EU Packaging and Packaging Waste Regulation (PPWR) requires that starting August 12, 2026, all packaging placed on the EU market must demonstrate compliance regarding four heavy metals and PFAS / Total Fluorine for food contact packaging. Additionally, companies must complete the corresponding packaging law registration and recycling reporting in target Member States. Failure to comply may result in customs detention, product delisting on platforms like Amazon and eBay, and fines of up to 4%–6% of annual turnover.


Relying on dual-accredited CMA and CNAS testing laboratories alongside years of experience in cross-border compliance services, JJR LAB provides EU-bound enterprises with regulatory interpretation, packaging chemical compliance testing, and EU EPR packaging law registration and reporting.

European Regulation PPWR Testing Services(图1)

What Packaging Does PPWR Cover?

The regulatory scope of PPWR is exceptionally broad—all packaging and packaging waste on the EU market are included, without distinction by material, industry, or product category. Classified by use, they fall into four categories:

1.Primary / Sales Packaging: Packaging in direct contact with the product and intended for the end user (e.g., beverage cans, toothpaste tubes).

2.Secondary / Grouped Packaging: Packaging designed to group multiple sales units together (e.g., shrink film around a 6-pack of beverages).

3.Transport Packaging: Used for logistics handling and protection (e.g., corrugated boxes, stretch wrap, pallets, strapping bands).

4.Service Packaging: Filled at the point of sale (e.g., takeout boxes, coffee cups).

Note: Transport and B2B industrial packaging (pallets, stretch wrap, cushioning materials, etc.) fall under the scope of PPWR and must be evaluated separately. However, containers used in road, rail, sea, and air transit themselves are excluded—though materials used inside containers to secure or protect products may still be regulated.


Heavy Metals Testing

Applicable Subjects

Primary Packaging / Secondary Packaging / Transport Packaging (pallets, stretch wrap, strapping bands) / Service Packaging / E-commerce Packaging. Substrates, printing layers, coatings, and adhesives are split into homogeneous materials for submission and testing.

Statutory Limits

Item

Limit

Sum of Pb + Cd + Hg + Cr⁶⁺

≤ 100 mg/kg (0.01%)


Fluoride and pfas testing

Food Contact Scenarios Covered

Tea bags, coffee capsules, baking paper, blister trays, composite films, greaseproof paper bags.

Trigger Logic

1.Total Fluorine (TF) Screening:  50 mg/kg (50 ppm)  Direct Release.

2.Total Fluorine > 50 mg/kg  Proceed to differentiate between organic fluorine and inorganic fluorine.

3.Organic Fluorine Exceeds Limits  Perform quantification of targeted PFAS monomers.


PPWR Food Contact Packaging Limits

Indicator

Limit

Any non-polymeric PFAS monomer

≤ 25 ppb

Sum of non-polymeric PFAS

≤ 250 ppb

Total Fluorine (including PFAS polymers)

≤ 50 mg/kg (50 ppm)

Total Fluorine > 50 ppm

Technical documentation must be attached to prove the source of fluorine (whether it is PFAS).

Special Note: Although non-food contact packaging currently has no numerical PFAS limits, Member State EPR authorities and buyer audits have begun requiring Total Fluorine reports. JJR LAB recommends issuing the "Heavy Metals + Total Fluorine" bundle for the same batch to avoid re-sampling.


EU EPR Packaging Law Registration and Reporting

PPWR does not exist in isolation; it is closely linked to the EPR (Extended Producer Responsibility) systems of various EU countries. Having testing reports alone is insufficient to complete customs clearance and market launch. You must complete EPR registration and obtain a packaging recycling registration number in target markets.

EPR Services:

1.Multi-Country Registration: Packaging law registration for major EU countries, including Germany (LUCID), France (CITEO), Spain, Italy, and the Netherlands.

2.Compliance Reporting: Guidance on annual recycling volume reporting and recycling fee payment.

3.Data Integration: Seamlessly link your chemical testing data into the EPR compliance database to handle spot checks and audits by market regulatory authorities.


Why Do Testing + EPR Together?

German customs and e-commerce platforms (such as Amazon) frequently require sellers to prove the environmental safety of packaging materials (i.e., testing reports) during audits. JJR LAB's one-stop "Testing + EPR" service ensures that your Declaration of Conformity (DoC) perfectly matches your administrative registration, completely eliminating account suspension risks caused by missing documentation.


Why Choose JJR LAB

1.Qualifications: Accredited laboratory by CNAS, CMA, and CPSC; chemical testing reports are mutually recognized across Chinese, US, and European platforms.

2.Capabilities: Actual testing for Heavy Metals / Total Fluorine / PFAS (where the targeted PFAS list covers the cross-list of EU 2025/40 and REACH). Simultaneously backed by a dedicated EPR regulatory team familiar with various national recycling systems.

3.Turnaround: Standard testing takes 5–7 working days, expedited takes 3 working days (depending on matrix); dedicated specialists follow up on registration and reporting.



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